Arc Realty Co. v. Commissioner
United States Tax Court
On June 24, 1932, petitioners, personal holding companies during the taxable years in issue, exchanged the gold notes which they held of the American Press for interim certificates representing 1,417 1/2 shares of Star 4 per cent second preferred stock. Said interim certificates were subject to certain restrictions. Between 1932 and 1934 additional interim certificates for 1,104 shares of Star were contributed to the capital of petitioner Lydiade.
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On June 24, 1932, petitioners, personal holding companies during the taxable years in issue, exchanged the gold notes which they held of the American Press for interim certificates representing 1,417 1/2 shares of Star 4 per cent second preferred stock. Said interim certificates were subject to certain restrictions. Between 1932 and 1934 additional interim certificates for 1,104 shares of Star were contributed to the capital of petitioner Lydiade. On July 2, 1934, petitioners received 2,521 1/2 shares of Star 4 per cent second preferred stock in exchange for their interim certificates. During…
1Opinion of the Court
Arc Realty Company, et al., 1 Petitioners, v. Commissioner of Internal Revenue, Respondent
Arc Realty Co. v. Commissioner
Docket Nos. 64689, 64690, 64691, 70296, 70297, 70298
United States Tax Court
34 T.C. 484; 1960 U.S. Tax Ct. LEXIS 133;
June 15, 1960, Filed June 15, 1960, Filed
Decisions will be entered under Rule 50.
On June 24, 1932, petitioners, personal holding companies during the taxable years in issue, exchanged the gold notes which they held of the American Press for interim certificates representing 1,417 1/2 shares of Star 4 per cent second preferred stock. Said interim certificates…
2Cases cited28 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Helvering v. Tex-Penn Oil Co.Supreme Court of the United States · 1937
- Commissioner of Internal Revenue v. Clarion Oil Co.Court of Appeals for the D.C. Circuit · 1945
- Aramo-Stiftung v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1949
- Kline v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1942
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